Singapore · Voluntary framework
Singapore Model AI Governance Framework
Singapore's voluntary Model AI Governance Framework from IMDA and the PDPC. Its four areas, the human involvement matrix, the ISAGO guide and who uses it.
The Model AI Governance Framework is Singapore's voluntary guide to deploying AI responsibly, published by IMDA and the PDPC. The second edition (January 2020) sets out four areas of practice and a probability and severity of harm matrix for deciding how much human involvement an AI-assisted decision needs. It carries no legal obligations, but it is the base that Singapore's generative AI and agentic AI frameworks build on.
What it is
The Model AI Governance Framework is Singapore’s practical guide to deploying AI responsibly. The PDPC released the first edition on 23 January 2019 at the World Economic Forum in Davos. The second edition followed on 21 January 2020, also at Davos, refining the first with industry examples, clearer guidance on human involvement and new measures for robustness, reproducibility and auditability.
The framework rests on two guiding principles. Organisations using AI in decision-making should make sure the process is explainable, transparent and fair. And AI solutions should be human-centric, with people’s interests, well-being and safety as the primary consideration. It is deliberately algorithm-agnostic, technology-agnostic, sector-agnostic and scale-agnostic, so the same structure works for a bank, a hospital or a retailer.
Two companions sit alongside it. The Implementation and Self-Assessment Guide for Organisations (ISAGO) turns the framework into questions an organisation can answer about its own practices. A Compendium of Use Cases shows how organisations have applied it.
Who it applies to
Any organisation deploying AI at scale, in Singapore or elsewhere. It is voluntary, and the framework itself says that adopting it does not absolve an organisation from complying with the law. In practice it is the vocabulary Singapore regulators and many Asian customers use when they ask how an AI system is governed. MAS lists IMDA’s Model AI Governance Framework among the national initiatives financial institutions may refer to.
What it requires
The framework is organised into four areas.
Internal governance structures and measures. Clear roles and responsibilities for the ethical deployment of AI, adapted from existing governance where possible. AI risk can sit inside the enterprise risk management structure, ethical considerations can go through an ethics review board, and the people with AI governance roles should be properly trained. The framework calls the sponsorship and participation of top management and the board crucial.
Determining the level of human involvement in AI-augmented decision-making. This is the framework’s best-known contribution. An organisation weighs the probability of harm against the severity of harm to an individual or organisation and uses the result to choose one of three approaches.
- Human-in-the-loop. A person retains full control and the AI only recommends.
- Human-over-the-loop. A person monitors and can step in when the system behaves unexpectedly.
- Human-out-of-the-loop. The AI decides and acts with no human oversight of execution.
High severity and high probability point towards human-in-the-loop. Low severity and low probability can justify human-out-of-the-loop. The framework is clear that the definition of harm and how probability and severity are computed depend on context, and that the choice should be revisited as circumstances and societal norms change.
Operations management. The disciplines across the AI lifecycle. Data accountability covers understanding data lineage, ensuring data quality and minimising inherent bias in datasets. Algorithm and model practices cover explainability, repeatability, robustness, regular tuning, reproducibility, traceability and auditability.
Stakeholder interaction and communication. Telling people that AI is in use, having a policy on what to explain and to whom, considering an option to opt out, giving people channels for feedback and review, testing the user interface, and communicating in language people can follow.
Key dates
- 23 January 2019. First edition launched.
- 21 January 2020. Second edition and ISAGO released.
The framework has not been reissued since. IMDA has extended the approach through the Model AI Governance Framework for Generative AI (May 2024) and the Model AI Governance Framework for Agentic AI (January 2026, updated May 2026).
How it relates to other frameworks
The generative AI and agentic AI frameworks are extensions of this one. The agentic framework in particular adapts the human involvement idea to agents, adding significant checkpoints for human approval and guarding against automation bias. AI Verify turns the shared principles into process checks and technical tests.
Outside Singapore, the four areas map closely onto the management system clauses of ISO/IEC 42001 and the Govern, Map, Measure and Manage functions of the NIST AI RMF. The probability and severity approach to human oversight is a practical way to meet the human oversight expectations that appear in most frameworks, including the EU AI Act’s requirements for high-risk systems. Organisations that already run one of those frameworks will find most of the work done.
Working with it in Aicura
Singapore framework content is available in Aicura on the Enterprise tier. An administrator enables it in Settings under Frameworks, where the available frameworks follow the subscription tier. Risk and impact assessments then draw on it, including the human involvement calibration, and governance policy reviews can be set to apply it.
The AI Register already records each system’s and agent’s human oversight level, such as human-out-of-the-loop, which is the framework’s own vocabulary. Assessment output is guidance for your judgement. It does not certify a system or declare it aligned with the framework.
A note on this page
This is Aicura’s reading of the framework, written to help you understand it. It is not legal advice and it is not the framework itself. Read the primary sources from IMDA and the PDPC, and take advice on how Singapore’s expectations bear on your organisation.
Last reviewed 16 October 2026. This page explains the framework to support your governance work. It is not legal advice; read the official source for the authoritative text.
Questions
Is the Singapore Model AI Governance Framework mandatory?
No. IMDA and the PDPC describe it as a living and voluntary framework. Adopting it does not take the place of obligations under Singapore law, including the Personal Data Protection Act. Sector regulators such as MAS point to it as a reference.
What is the difference between human-in-the-loop, human-over-the-loop and human-out-of-the-loop?
Human-in-the-loop means a person actively makes the final decision with the AI providing recommendations. Human-out-of-the-loop means the AI decides with no human oversight over the execution. Human-over-the-loop means a person monitors and can adjust or take over when the system behaves unexpectedly. The framework uses the probability and severity of harm to choose between them.
What is ISAGO?
The Implementation and Self-Assessment Guide for Organisations is the framework's companion. IMDA and the PDPC developed it with the World Economic Forum's Centre for the Fourth Industrial Revolution and input from more than 60 organisations. It lets an organisation check how closely its practices align with the framework.
Has the framework been replaced by the generative AI and agentic AI frameworks?
No. The 2024 generative AI framework and the 2026 agentic AI framework build on it. Its four areas still apply to traditional AI systems and remain the reference point the later frameworks extend.
Use Model AI Governance Framework in your Aicura reviews
Enable Model AI Governance Framework as a framework in Aicura on the Enterprise plan and above, on top of the AI register every plan starts with.
